Privacy Notice

Pursuant to Federal regulations, we are providing this Privacy Notice to all of the individual clients of our brokerage firm and its affiliated entities. Further, the USA PATRIOT Act, which imposes Anti-Money Laundering Requirements on brokerage firms and financial institutions, requires that we ask you to provide us with various identification documents or other information in order for us to be permitted to open or maintain an account for you or to effect transactions for you. In addition, we may make inquiries of other organizations for information about you in order to fulfill our responsibilities under Federal regulations.

The Information We Collect About You. The non-public personal information we collect about you (your “information”) comes primarily from the account applications or other forms you submit to us. We may also collect information about your transactions and experiences with us or our affiliates relating to the products or services we provide.In addition, depending upon the products or services you require, we may obtain information from consumer reporting agencies.

Our Disclosure Policies. We do not disclose your information to anyone, except as permitted by law and as required by Hilltop Securities Inc., our clearing firm, or Cowen and Company, our servicing agent, as necessary to perform such services in connection with your account. This may include sharing your information with non-affiliated companies that perform support services for your account or process your transactions with us. Additionally, it may include disclosing your information pursuant to your express consent, to fulfill your instructions, or to comply with applicable laws and regulations.

Our Information Security Policies. We limit access to your information to those of our employees and service providers who are involved in offering or administering the products or services that we offer. We maintain physical, electronic, and procedural safeguards that are designed to protect your information.

If our relationship ends, we will continue to treat the information as described in this Privacy Notice.